Kevin Abikoff wrote an explanatory article published on the website of ETHIC Intelligence, a leading certification agency specializing in anti-corruption compliance programs.
In the article, “What are the recent World Bank Sanctions Board decisions? The Necessity of Pre-existing Effective Compliance Programs,” Abikoff explained the implications of the Board’s first seven opinions released on May 30, 2012.
“The first seven public decisions demonstrate the Sanctions Board’s awareness of and appreciation for broader global compliance trends,” he wrote. “These decisions also emphasize the Board’s willingness to take an independent view of the submissions presented to them and to provide a detailed analysis of the matters under submission.”
Abikoff also discussed what the Board expects from companies with respect to internal investigations; how the Board considers an effective compliance program defense to vicarious corporate liability; what happens if compliance programs are modified in response to alleged corruption; and whether mitigation is meaningful.